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SEC 10c-1a – updated SLATE Spec analysis and what firms need to know

Written by Tom Veneziano | Jul 22, 2025 12:06:40 PM

On June 27th FINRA published their updated specs for reporting to SLATE for SEC rule 10c-1a. In this article, Thomas Veneziano, Head of Product, Americas, explores how the regulation and these latest changes will impact securities finance operations globally – and what industry participants need to do about it.

What’s happening

SEC 10c-1a is the incoming regulatory reporting of securities finance transactions in the US, similar in its objective to the existing Securities Financing Transactions Regulation (SFTR) regime in the European Union.

The SEC (which sets the overall rules and standards for the securities industry in the United States) has set the implementation date as January 2nd, 2026 – so only five+ months from today. Although FINRA (which enforces SEC rules at the operational level) has requested a delay until September 2026, the SEC has not yet approved the request and therefore the window for preparation as it stands is closing in a few months.

Even if 10c-1a were delayed until September 2026, the regulatory regime’s impact on securities finance operations within the US, as well as any global firms that fall in its regulatory ambit, are substantial.

Pirum and S&P Cappitech Market Intelligence have undertaken an extensive review of SLATE version 1.2, to confirm what needs to happen between now and then for companies to ensure full compliance. This article contains a high-level summary of our deep-dive analysis of the specs and impacts for industry participants – for more details, get in touch with us from the link below.

Answer the build or partnership question

For industry participants that have yet to decide on the build or buy question, the task implied by build is sizeable, if not prohibitive. To achieve full compliance, even within the extended September 2026 timeframe, firms need to:

  • Design and build out files according tothe specific FINRA Specs
  • Perform their own eligibility checks, to identify the loans that are reportable and those that are not in scope
  • Build a way to connect directly to SLATE, which is a challenge for anyone at present given FINRA have yet to release their connectivity documentation

And that’s just to give a few, high-level examples. The Technology build related to the three points will require considerable investment in the remaining months. To do all three successfully in the time remaining, while continuing BAU – let alone embarking on other strategic projects – will challenge even the most efficient and agile firms.

The other option is to partner with a tried-and-tested regulatory reporting vendor. This reasoning includes the benefits of:

  • Leveraging the vendor’s inbuilt connectivity
  • Obviating the need for internal builds – and the related drain on resources
  • Increasing time to market ahead of the all-important go-live dates, whether January or September 2026.

Impact of the latest Schema changes

The most important takeaways from the latest updates to the SLATE Schema included:

  • Definition and additional error codes
  • String lengths for various fields
  • Multiple Schema changes
  • New collateral type code MIX for pooled loans
  • Taxonomy on specific Benchmark names
  • Removal of response times

These changes affect every desk in scope for reporting under 10c-1a, in the US and globally. While this should be the final version from FINRA, the industry take is that the timeline is still in flux.

Whether the Specs are updated again or the timeline is changed, Pirum and S&P Cappitech’s in-built and industry-wide connectivity, minimizes our clients’ point of entry and reduces the impact of any future changes to FINRA specifications.

Compliance on a solid, interoperable, and global foundation

Pirum and S&P Cappitech enable clients to leverage an efficient and accurate solution for Securities Lending reporting. The 8 years of experience from a joint SFTR solution have shown that, for a regulatory reporting solution in the securities finance space, ease of connectivity and standardization of data, as well as clients’ ability to do any types of reconciliations, are of paramount importance.

Our joint SFTR solution is today used by most of the industry, having established itself as the benchmark for delivering regulatory reporting solutions for securities finance.

This existing foundation and expertise make us perfectly positioned to speed up client readiness for 10c-1a and have them compliant with minimal work on their side.  

For an overview of our solution and impact to the industry of the changes please contact us.